Independent quality assurance & Skilled Person support

Forensic File Reviews, AML Assurance & Scalable Regulatory Remediation

When regulatory scrutiny intensifies, firms can not rely on high-level checklists or superficial sampling. Drawing on senior experience across Section 166 Skilled Person reviews (KPMG, Deloitte, FSCS), institutional remediations and complex advice networks, we provide independent, forensic oversight. From defined benefit pension transfers and SIPP due diligence to complex Ultimate Beneficial Owner (UBO) AML audits, we deliver defensible quality assurance that withstands regulatory and Ombudsman challenge.

Moving Beyond Checkbox Compliance

Past-business reviews and regulatory remediations are among the most operationally demanding tasks an advisory firm, wealth manager or network principal can undertake. The trigger may be an FCA supervisory notice, a Section 166 appointment, a thematic review or internal risk identification. Whatever it is, the challenge is the same: delivering forensic, consistent analysis across large case volumes without disrupting day-to-day business.

With a background in high-stakes institutional remediations, we design and execute review methodologies that satisfy strict regulatory scrutiny while keeping the advice context grounded in commercial reality.

We support Compliance Directors, Chief Risk Officers and SMF holders on three priorities:

  • Methodology Defensibility: Consistent assessment templates aligned with the FCA Handbook (COBS, SYSC, DISP) and current Ombudsman approach.
  • Technical Depth: Evaluating complex pension transfer advice (DBAAT), non-standard SIPP assets and investment suitability at a peer-to-peer level.
  • Root-Cause Remediation: File reviews that identify the underlying operational or supervisory failure, so the firm fixes its systemic risk permanently.

Review sequence

  1. 1 Remediation Architecture
  2. 2 Forensic File Reviews
  3. 3 AML / UBO Audits
  4. 4 Redress & Board MI

What the review covers

A

Section 166 & Past-Business Reviews

Objective: Structured, independent quality assurance to satisfy Skilled Person mandates and regulatory undertakings.

  • Designing and executing cohort sampling methodologies across historical books of business.
  • Managing end-to-end case workflows: file acquisition, reconstruction of contemporaneous records, gap analysis and final determination.
  • Acting as a senior QA layer to calibrate internal review teams and eliminate reviewer inconsistency.

B

Pensions & Investment Suitability Reviews

Objective: Assessing advice files against COBS suitability standards and Consumer Duty expectations.

  • Defined Benefit Transfers: Forensic assessments of DB transfer advice under COBS rules and DBAAT.
  • SIPP & Non-Standard Investments: File audits covering operator due diligence, liquidity and non-standard asset suitability.
  • Decumulation & Retirement Income: Evaluating UFPLS, flexi-access drawdown designations, cash-buffer sustainability and tax-drag impacts.
  • Ongoing Servicing Audits: File-by-file reconciliations verifying that recurring adviser charges are supported by delivered annual reviews.

C

Financial Crime, AML & Complex UBO Reviews

Objective: Auditing entity structures for full adherence to AML and KYC requirements.

  • Forensic investigation of complex corporate, multi-jurisdictional, trust and partnership structures to identify Ultimate Beneficial Owners.
  • Remediation of legacy AML records, identification and verification deficiencies, and Source of Wealth / Source of Funds evidence.
  • Stress-testing onboarding and financial crime controls against SYSC and Joint Money Laundering Steering Group (JMLSG) guidance.

D

Redress Calculation & Remediation Governance

Objective: Making sure client detriment is quantified accurately and fairly.

  • Calculating financial loss across complex pension and investment cases, returning customers to the position they would have been in but for the unsuitable advice.
  • Market-movement and settlement-lag redress calculations in line with Ombudsman approach.
  • Senior management remediation packs, root-cause MI dashboards and defensible closure reports for regulatory submission.

Remediation Workflow: End-to-End Delivery

Our structured review lifecycle maintains integrity from initial scoping to final board sign-off.

  1. 01

    Scoping & Calibration

    Review regulatory notices, design the scoring rubric, calibrate reviewer benchmarks.

  2. 02

    Forensic File Review & Discovery

    Evidence reconstruction, fact-find analysis, suitability testing, AML/UBO audit.

  3. 03

    QA & Independent Calibration

    Dual-review sample checks, technical SME escalation, determination sign-off.

  4. 04

    Redress Modelling & Client Communication

    DISP-compliant response drafting, precise loss calculation, FOS-ready files.

  5. 05

    Root-Cause MI & Governance Closure

    Senior management dashboard, operational process fixes, regulatory submission.

Proven Remediation Track Record

Our expertise is founded on hands-on delivery across major UK financial institutions and regulatory bodies.

Section 166 Reviews (KPMG / Deloitte)

Senior reviewer leading entity investigations, group structure analysis and file QA across high-volume insurance and regulatory review programmes.

FOS Pension Casework

Direct investigation of suitability complaints, SIPP operator due diligence and redress calculations at the Financial Ombudsman Service.

Advisory Network Oversight

Leading complaint remediations, writing DISP final responses, reviewing DB transfers and embedding Consumer Duty root-cause MI.

Investment & Claims Audits (FSCS / Deloitte)

Analysing recommendations for non-standard investments, reviewing EMIR obligations across complex structures and managing executive dispute investigations.

Why partner with us

  • Level 6 Pension Expertise

    CISI qualified in Pension Transfers & Planning Advice (MCSI), with the technical authority to challenge or defend complex pension recommendations.

  • Ombudsman-Tested Judgement

    Informed by direct experience inside the Financial Ombudsman Service, so our determinations anticipate how adjudicators evaluate fair outcomes.

  • Pragmatic Integration

    We work independently or alongside your in-house compliance and legal teams, delivering calibrated, defensible files without excessive operational disruption.

Need Senior Expertise for an Upcoming File Review or Remediation?

Whether you're facing a formal Section 166 review, running a past-business pension audit or clearing a backlog of complex file reviews, contact Compass Compliance Consulting for confidential, senior-level support.